Robin Mathew QC New Square Chambers considers who should open a tax appeal hearing if the Crown alleges dishonesty by the taxpayer
Should the Crown or the taxpayer/appellant open proceedings in a tax appeal where the appellant's honesty is called into question? Does it matter? In my view it sometimes matters very much and indeed may be of vital importance in ensuring the appellant's case is properly put.
Yet there is no modern judicial guidance (that is to say from the High Court and above) for advocates or the Tribunals on this significant point.
33 years ago the then Master of the Rolls Lord Denning set out a basic rule for income tax appeals ...
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Robin Mathew QC New Square Chambers considers who should open a tax appeal hearing if the Crown alleges dishonesty by the taxpayer
Should the Crown or the taxpayer/appellant open proceedings in a tax appeal where the appellant's honesty is called into question? Does it matter? In my view it sometimes matters very much and indeed may be of vital importance in ensuring the appellant's case is properly put.
Yet there is no modern judicial guidance (that is to say from the High Court and above) for advocates or the Tribunals on this significant point.
33 years ago the then Master of the Rolls Lord Denning set out a basic rule for income tax appeals ...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes: